Jill A. Pryor

In Thamotar v. U.S. Attorney General, Pryor's opinion granted a petition for review after the immigration judge denied asylum but granted withholding of removal without reconsidering the asylum denial anew. The opinion required the agency to address reasonable alternatives for family reunification under the governing regulation.

“When an asylum applicant is denied asylum but granted withholding of removal, 8 C.F.R. § 1208.16(e) requires reconsideration anew of the discretionary denial of asylum, including addressing reasonable alternatives available to the petitioner for family reunification.”

In Tanner v. Stryker, Pryor affirmed summary judgment on the FMLA claims because Tanner offered no evidence from which a reasonable jury could find retaliation or interference.

“Nonetheless, he has offered no evidence from which a reasonable jury could conclude that his former employer engaged in FMLA retaliation or interference.”

In United States v. Melchor Munoz, Pryor vacated a denaturalization judgment because the district court’s judicial-estoppel findings about when the defendant’s drug trafficking began lacked record support.

“But these findings are clearly erroneous because they lack evidentiary support in the record.”

In Doe v. United States, Pryor's opinion held that the FTCA intentional-tort exception did not bar negligence claims arising from alleged abuse at a government-owned childcare center. The alleged government breach was of a duty independent of the later intentional misconduct, so the case was remanded.

“Instead, we hold that the intentional tort exception, § 2680(h), does not apply when an FTCA claim arises out of the government’s breach of an independent duty which, in turn, led to an excepted intentional tort.”